Brief Fact Summary. Two property owners contested ownership of a piece of land situated along the Missouri River on the Nebraska and Missouri border. A Nebraska court ruled that the land in question was located in Nebraska and issued judgment as to the ownership of the land. The losing party then filed suit in Missouri, seeking to quiet title to the land.
Synopsis of Rule of Law. A judgment is entitled to full faith and credit, for res judicata purposes, even as to questions of jurisdiction, where the second court’s inquiry disclosed that those questions have been fairly and fully litigated and finally decided in the court which rendered the original judgment.
Courts of one State are completely without jurisdiction directly to affect title to land in other States.View Full Point of Law
Issue. Whether a state court judgment is entitled to full faith and credit for res judicata purposes even though a later court finds that the initial state court lacked jurisdiction over the suit.
Held. Yes. The Supreme Court reversed the judgment of the court of appeals. Full faith and credit requires every state to give to a judgment at least the res judicata effect which the judgment would be accorded in the state which rendered it. A judgment is entitled to full faith and credit, even as to questions of jurisdiction, where the second court’s inquiry disclosed that those questions have been fairly and fully litigated and finally decided in the court which rendered the original judgment. Since the question of subject matter jurisdiction had been fully litigated in the original forum, the issue could not be retried in a subsequent action between the parties. Concurrence. Justice Thomas C. Black (J. Black) concurred. J. Black’s concurrence stated that he would not uphold the judgment of the Nebraska court if it were later found that the land in question was actually located in Nebraska because no state has power to make a determination binding on the other as to which state the land is in.
Discussion. Here the court is stating the perplexing rule that even if it is later determined that a state court lacked subject matter jurisdiction or personal jurisdiction, so long as those jurisdictional issues were contested and ruled upon by the state court, the state court’s judgment will stand. The court noted however, that this rule is subject to doctrines of federal pre-emption, or sovereign immunity.